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Exceptions from Pretreatment Regulations for Touch-Up Plating Operations


40 CFR 433.10(a) establishes the applicability of federal pretreatment regulations governing wastewater discharges from the metal finishing point source category. The literal language of that section provides that if a facility performs any of six metal finishing operations then the regulations apply to discharges from those operations as well as discharges from any of 40 other process operations. Apparently, there does not have to be a discharge from the six metal finishing operations for the regulations to apply. The regulations seem to apply if there is a discharge from one of those six operations, one of the 40 process operations or both.

Does anyone know of an exception from these federal regulations for touch-up/minor plating operations?

For example, suppose electroplating (one of the six metal finishing operations) occurs at a facility and there are discharges from two of the 40 listed process operations. However, there are no discharges from the electroplating operations. The electroplating operations are not a permanent, ongoing process. Such work is only done to touch-up components which have been plated elsewhere (Ex: a component plated by an off-site plating company may become chipped or scratched in the manufacturing/transportation process requiring minor repair or touch-up work). There is no permanently affixed equipment at the site to do electroplating. Rather it is a portable operation that is rolled on a cart to the area of the plant where the part needing to be touched-up is located. Touch-up work occurs on two or three parts per month and the entire plating operation on any part takes about 30 minutes to complete. One person does all the work.

It does not seem that the federal categorical pretreatment standards were meant to apply to touch-up plating operations such as this. Can anyone confirm that and why? Thanks in advance.

David Fountain
- Charlotte, North Carolina

There is considerable relief from the paperwork of EPA since you would fall into the category of a conditionally exempt generator. You will be a generator and at some time you will have to send haz waste to a treatment facility and a secure landfill.

Another major help is "satellite accumulation points". This is a major relief from the pain in the --- requirements, but there are a few simple, very specific, rules that must be followed.

Exempt, NO way. Reliefs, Yes.

James Watts
- Navarre, Florida

Hello. I think that your really have two issues here. First, what is in your wastewater you are looking to discharge? Second, what regulations do you need to comply with? Your first question can be answered by looking at the process(es) you are using. This can make a difference in what applies to you. Second, while there is wastewater discharge relief from the pretreatment standards at certain low levels of discharge, they consider the volume of discharge from your entire plant. Also, you may very well have even more stringent local POTW regulations. If your operations are minimal, I would definitely investigate evaporation technology or even extreme P2 measures and drum and ship.

Mike Wells
plating shop - jamestown, New York

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